# TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 120161009
- **title:** TRANSCONTINENTAL GAS PIPE LINE COMPANY — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-11-02
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.243(b)(1).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120161009
**body:**

Notice of Probable Violation involving TRANSCONTINENTAL GAS PIPE LINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.243(b)(1). The case was opened on 2016-11-02 and is reported as closed as of 2017-06-27. Proposed civil penalty: $39,700. Assessed civil penalty: $39,700. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120161009_Final Order_06272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_Final%20Order_06272017.pdf

120161009_Final Order_06272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_Final%20Order_06272017_text.pdf

120161009_NOPV PCP_11022016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_NOPV%20PCP_11022016.pdf

120161009_NOPV PCP_11022016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120161009/120161009_NOPV%20PCP_11022016_text.pdf

120161009_Final Order_06272017_text.pdf

June 27, 2017
Mr. Alan S. Armstrong
President and Chief Executive Officer
The Williams Companies, Inc.
One Williams Center
Tulsa, OK 74172
Re: CPF No. 1-2016-1009
Dear Mr. Armstrong:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and assesses a civil penalty of $39,700 against your subsidiary, Transcontinental Gas
Pipe Line Company. This is to acknowledge receipt of payment of the full penalty amount, by
wire transfer, dated November 16, 2016. This enforcement action is now closed. Service of the
Final Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R.
§ 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Director, Eastern Region, Office of Pipeline Safety, PHMSA
Ms. Stephanie Timmermeyer, VP, Safety and Regulatory Compliance, Transcontinental
Gas Pipe Line Company, 525 Central Park Drive, Oklahoma City, OK 73105
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
_________________________________________
In the Matter of )
Transcontinental Gas Pipe Line Company, ) CPF No. 1-2016-1009
a subsidiary of Williams Partners, LP, )
)
)
)
Respondent. )
_________________________________________ )
FINAL ORDER
From September 15 through 19, 2014, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of
Transcontinental Gas Pipe Line Company, LLC (Transco or Respondent), a subsidiary of
Williams Partners, LP, related to Transco’s replacement of sections of mainlines A, B, and C
within Unit 2881 in Owings Mills, Maryland. Transco’s system has approximately 10,200 miles
of pipeline extending from South Texas to New York City, and is a major provider of natural gas
to the Eastern United States.1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated November 2, 2016, a Notice of Probable Violation and Proposed Civil Penalty
(Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Transco had
violated 49 C.F.R. § 192.243, and proposed assessing a civil penalty of $39,700 for the alleged
violation.
Respondent did not contest the allegation of violation and paid the proposed civil penalty of
$39,700. In accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate
Administrator to make a finding of violation and to issue this final order.
FINDING OF VIOLATION
Transco did not contest the allegation in the Notice that it violated 49 C.F.R. Part 192, as
follows:
1 See http://co.williams.com/gulf_coast/transco/ (last accessed April 20, 2017).



CPF No. 1-2016-1009
Page 2
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.243, which states in
relevant part:
§ 192.243 Nondestructive testing.
(a)…
(b) Nondestructive testing of welds must be performed:
(1) In accordance with written procedures; and
(2) …
The Notice alleged that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to
nondestructively test a weld in accordance with its written procedure, which references
American Petroleum Institute Standard (API Std.) 1104. Specifically, Transco did not place an
image quality indicator (IQI) across the repaired area of a repair weld as prescribed in API Std.
1104, subsection 11.1.6, “Placement of IQIs.”
Respondent’s WilSOP Operations & Maintenance Manual Procedure 90.09.01 – Nondestructive
Testing of Welds states: “The purpose of this procedure is to establish the minimum requirements
for Nondestructive Testing (NDT), inspection, and/or evaluation to meet or exceed NDT
requirements as set forth in American Petroleum Institute (API) 1104, latest Pipeline and
Hazardous Materials Safety Administration (PHMSA) accepted edition.” Furthermore, API Std.
1104, section 11.1.6.1, “Film” describes the placement of IQI on films to be interpreted, and
states, in pertinent part, that “[w]hen a repaired weld is radiographed, an additional IQI shall be
placed across each repaired area.”
During the inspection, PHMSA requested Line C NDT records for any welds that required
repair. Transco provided x-ray files and records associated with ML-20 and its repair, ML-20R.
Upon review of the files and records, the PHMSA inspector found no evidence of an IQI being
placed across the repaired area of the weld. Transco was alerted to this issue and subsequently
re-radiographed the repaired weld ML-20R with proper IQI placement, as required by its written
procedures and API Std. 1104.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 192.243(b)(1) by failing to
nondestructively test a weld in accordance with its written procedure that references API Std.
1104, which requires an additional IQI to be placed across each repaired area of a weld that is
radiographed.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any



CPF No. 1-2016-1009
Page 3
related series of violations.2 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect
that the penalty may have on its ability to continue doing business; and the good faith of
Respondent in attempting to comply with the pipeline safety regulations. In addition, I may
consider the economic benefit gained from the violation without any reduction because of
subsequent damages, and such other matters as justice may require. The Notice proposed a total
civil penalty of $39,700 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $39,700 for Respondent’s violation of 49 C.F.R.
§ 192.243(b), for failing to nondestructively test a weld in accordance with its written procedure
which references API Std. 1104. As previously discussed, contrary to respondent’s WilSOP
Operations & Maintenance Manual Procedure 90.09.01 – Nondestructive Testing of Welds,
Transco did not utilize an IQI over the repaired area of the weld. Transco neither contested the
allegation nor presented any evidence or argument justifying a reduction in or elimination of the
proposed penalty. Accordingly, having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $39,700 for violation of 49 C.F.R.
§ 192.243(b)(1).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $39,700. Transco paid the full
penalty amount by wire transfer on November 16, 2016.
The terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
June 27, 2017
___________________________________ _________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
2 These amounts are adjusted annually for inflation. See Pipeline Safety: Inflation Adjustment of Maximum Civil
Penalties, 82 Fed. Reg. 19325 (April 27, 2017).
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